Environmental Compliance Assurance

The ongoing process of comparing requirements to 1) records of past activities or conditions or 2) current observations.

 
Compliance assurance often involves executing what is described as a “compliance check”.  Deciding what to check and how to check it is typically best determined through the development of of a risk-based compliance assurance strategy.  Your strategy can be simple!

An ongoing (or periodic) check method can be designed that combines the backward-looking approach of a compliance audit with the periodicity of a task management process.  Checks can be assigned to someone other than the task performer, resulting in a check-and-balance system.

Checks should be developed by taking the time to specifically describe the records and documentation that should be checked, and exactly how to check them against the requirements – this is key!  Written effectively, a senior environmental auditor is not needed to conduct the checks.  Instead, almost anyone familiar with the equipment could do so.  See our summary below of how a task/audit/ongoing check system works (in general) and contact us to learn more about how JBE can help you organize, execute, or improve your compliance systems.

TAble

 

 

 

 

 

 

 

 

References

  • “Secrets to Meaningful, Sustainable and Efficient Regulatory Task Development for Compliance Certification,” NPRA, 2006, Savage, Alan; McGuire, Lynn, and Beath, John.
  • “Use Periodic Checks to Demonstrate Title V Compliance,” CEP, February 2004, Beath, J.M., and McCarthy, C.J.
  • “Practical Methodology for Addressing Ongoing Title V Compliance Certification – A Refinery Case Study,” NPRA, 2002, Beath, J.M., Stern, P.C.
  • “Rightsize Your Environmental Management System,” CEP, May 2001, Beath, J.M.